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lly, Respondents/Defendants. EMERGENCY MOTION FOR REVIEW OF ORDER DENYING STAY Pursuant to Florida Rule of Appellate Procedure 9.310(0, Petitioner Jeffrey Epstein, the plaintiff/counter-defendant below, files this motion for review of the circuit court's Order entered March 8, 2018 denying a stay of trial cour
(the Honorable Donald Hafele) has just made two rulings which warrant extraordinary relief. The first ruling in an Order of March 8, 2018, denying Epstein's Motion to Remove Case from Trial Docket in I In compliance with this Court's Administrative Order No. 2014-1, the Petitioner has contemporaneousl
Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST
arately. (App. 19)6. The court denied Epstein's ore tenus motion for stay. and this motion for review of that denial follows. (App. 20). ARGUMENT I. EPSTEIN IS LIKELY TO SUCCEED ON THE MERITS OF HIS MANDAMUS PETITION BECAUSE THE CIRCUIT COURT MUST REMOVE THE CASE FROM THE TRIAL DOCKET IN ORDER TO COMPL
Y. Mellon, 175 So. 3d 305, 306 (Fla. 3d DCA 2014) (final judgment reversed because case noticed for trial before answer to counterclaim was filed); Precision Constructors, Inc. v. Vallee, Constr. Bifurcation is improper here, because the issues presented by the claim and counterclaim are so inextricably intertwined that it
ockenbach FBN Rachel J. Glasser Primary: Primary: Primary: Seconda Seconda Seconda Trial & Appellate Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 23 EFTA00793715 CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman
cing investors he had negotiated multi-million settlements in high-profile cases. Three of Edwards' clients at the time alleged tort claims against Epstein, which Epstein ultimately settled. Based on publicly available information about 3 All background information is derived from the complaints and Jo
Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST
Y. Mellon, 175 So. 3d 305, 306 (Fla. 3d DCA 2014) (final judgment reversed because case noticed for trial before answer to counterclaim was filed); Precision Constructors, Inc. v. Yalta: Constr. Corp., 825 So. 2d 1062, 1063 (Fla. 3d DCA 2002) (judgment vacated because failure to adhere strictly to the mandates of Rule 1.44
IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 LT Case No: 502009CA0408003C3C3OCNIB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. REPLY TO RESPONSE TO EME
Civil Procedure, and unequivocal legal precedent interpreting the same clearly against him, Edwards levels false and misleading accusations against Epstein and injects impertinent allegations into his argument in an obvious attempt to divert the Court from its inevitable decision. Throughout his Respon
18-0762 LT Case No: 502009CA0408003C3C3OCNIB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST
final judgment would be insufficient to remedy the rule's provisions t re q g -in a 50-day hiatus between trial and service of the last pleading); Precision Constructors, Inc., 825 So. 2d at 1063 (judgment vacated because failure to adhere strictly to the mandates of Rule 1.440 is reversible error). Absent mandamus relie
Entities connected to both Jeffrey Epstein and Precision Constructors, Inc.

George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Naomi Campbell
PERSON
Chris Tucker
PERSONPalm Beach County Courthouse
LOCATIONMarc S. Nurik
PERSON
Melbourne
LOCATION
Scott J. Link
PERSON
Searcy
PERSONDonald W. Hafele
PERSON
Bennett
PERSONNichole J. Segal
PERSONDenny
PERSONBurlington & Rockenbach
ORGANIZATIONFifteenth Judicial Circuit
ORGANIZATIONFOURTH DISTRICT
LOCATION